The following was written by AFCCE FCC Liaison Don Everist:
Ben Dawson has made a cursory examination of WT Docket No. 13-238 (see 13-238 NR (10-20-14) ). He directs attention to Paragraphs 145 and 181 regarding replacement structures, etc. :
145. Section 6409(a) includes a number of undefined terms that bear directly on how the provision applies to infrastructure deployments. Below, we address the meaning of “wireless tower or base station,” “transmission equipment,” “collocation,” and “substantially changes the physical dimensions.”
181. We agree with Alexandria et al., however, that “replacement,” as used in Section 6409(a)(2)( C), relates only to the replacement of “transmission equipment,” and that such equipment does not include the structure on which the equipment is located. (Alexandria et al. Comments at 31 (arguing that replacement of a tower is not a “modification” of it and that Congress knew how to address “replacement” when that was its intent).
Even under the condition that it would not substantially change the physical dimensions of the structure, replacement of an entire structure may affect or implicate local land use values differently than the addition, removal, or replacement of transmission equipment, and we find no textual support for the conclusion that Congress intended to extend mandatory approval to new structures. Thus, we decline to interpret “eligible facilities requests” to include replacement of the underlying structure.
Ben recommends that AFCCE consider a Petition for Reconsideration. If you are so inclined please leave a comment or contact me.
The following was written by Steve Crowley, PE, chairman of the AFCCE Rules and Standards Committee:
On September 30 the FCC adopted a Notice of Proposed Rulemaking proposing, among other things, changes to Part 15 rules governing unlicensed operation in the TV band (TV white space), and new rules for operation in the duplex gap and guard bands of the forthcoming 600 MHz mobile band. The stated intent is to “allow for more robust service and efficient spectral use without increasing the risk of harmful interference to authorized users.”
The Notice can be found here: FCC-14-144A1 .
In addition to my role as AFCCE Secretary, I’m Chairman of its Rules and Standards Committee. I’m soliciting input from those who would like AFCCE to comment in this proceeding. If you have comments to suggest, please make them as comments to this post.
I’ll volunteer to serve as editor. Once views are expressed, I’ll work with those commenting to facilitate consensus and assemble the views into a draft filing. As a check, I propose to send the draft to the AFCCE Board of Directors for final approval.
The FCC comment deadline is 45 days after the date of publication of the Notice in the Federal Register. (Reply comment, 65 days). To facilitate a timely comment filing, please send any comments and proposed text by October 31, 2014. If there are any questions, please contact me at Secretary@afcce.org. Check back here for updates on this topic.
Wednesday, September 24, 2014
Web-Based Engineering Tools
What web-based services do you offer your clients? AFCCE members Mark Colombo (rabbitears.info) and Mike Rhodes (fccinfo.com) will discuss some of the enhanced query and analysis features on websites they maintain, enabling client-side functionality with more detail than FCC.gov web-based tools. Utilizing official FCC database sources, these services are made available at no cost to their users. Mark and Mike will discuss some of the motivating factors and implementation challenges they experienced along the way. They will also discuss how offering such services can have the potential of leading to new business opportunities as well as improvements in time management, each having a positive effect on profitability.
Presentation slides from the meeting can be downloaded here:
September 2014 Luncheon Presentation – FCCInfo.com Continue reading
From Radio World, Sept. 5, 2014:
AM systems manufacturer Kintronic Labs has several suggestions
for how the FCC can help revitalize the AM band. President Tom King plans to share those with Commissioner Ajit Pai and Audio Division Chief Peter Doyle in a meeting this month.
In advance of that meeting, King is promoting an “open letter to the industry” in which he ask broadcasters to contact Pai and Doyle in support of his recommendations, to let them know “how imperative it is that these measures be implemented on a fast approval track” to make AM competitive with FM. Here’s the letter: Kintronic Letter
The manufacturer has a keen interest in AM revitalization; its products are used in numerous facilities, and the company markets itself as “the oldest continually operating AM antenna system provider in the U.S.” Founder Louis King resigned from RCA in 1949 as an AM high-power transmitter design engineer, obtained his PE license and established a business as a regional broadcast consulting engineer that grew into Kintronic Labs. (Read a company history.)
Among the items listed by Tom King for urgent action are these that go beyond what many commenters have suggested:
-Establishment of mandatory minimum technical standards for AM receivers to become effective “as soon as January 2016.” In a demo, he plans to compare CQUAM AM stereo reception with a local FM station as well as the effects of adjusting AM bandwidth from 2.5 to 10 kHz in 2.5 kHz steps. He provides a list of specific minimum allowable performance specifications for all AM receivers, including a low internal noise floor, high RF sensitivity, selectivity and dynamic range and highly effective noise cancellation.
-FCC authorization of AM synchronous boosters, a technically challenging idea that has received less attention than FM translator discussions.
King also urges the commission to enforce RF limits for consumer electronics devices, noting the worsening electromagnetic environment for AM.
From Tom Taylor NOW, Sept. 9:
An AM quality manifesto from Tom King at Kintronic.
He’s pitching three key ideas, starting with a widespread problem that’s going to be very hard to put back in the bottle – interference from “the power distribution industry and [products sold by] the consumer electronics industry.” King says the FCC simply isn’t enforcing its existing rules, “resulting in a constantly worsening electromagnetic environment” for AM. Not only are lights and power lines a problem – so are computers and smartphones, which all contribute to the noise that makes AM reception scratchy. King’s point #2 is “the need for parity between AM and FM receivers through the establishment of minimum technical standards for AM receivers.” King’s not the first engineer to showcase how good AM can sound, and it really can. He’s pointing toward engineering questions like the noise floor, sensitivity of the receiver and noise rejection. (King’s also harking back to AM stereo, to put the medium on-par with FM stereo.) Point #3 is “the need for FCC authorization of AM synchronous boosters.” Tom King says “unlike FM translators, such on-channel boosters would serve to increase the AM stations’ audiences while maintaining the future viability of the band.” If those sound like worthy goals, King says “we need the full support and backing of you, the AM broadcasters, to be able to communicate to FCC Commission Ajit Pai and Audio Media Chief Peter Doyle.” Tom’s asking supporters to email the simple message “I approve” to KTL@Kintronic.com.
On January 22, 2013, SSR Communications, Inc. (“SSR”) filed a petition for Rulemaking to create a new Zone II FM broadcast station class, or “C4” allocation, and amend certain technical rules for the FM broadcast service.
The petition is here: Class C4. The FCC has extended the deadline for filing statements in support of or in opposition to the SSR Petition by one month, until September 18, 2014. The deadline for filing replies to such statements is October 3, 2014. See DA-14-1182A1. AFCCE members interested in this matter may post their comments on the web page.
The 2014 Annual Meeting of the Association was a major success, assisted by mostly cooperative late spring Nova Scotia weather and a wonderfully comfortable venue–The Prince George Hotel, Halifax. Members enjoyed a bus ride through the Atlantic Coast countryside to the Nautel transmitter plant, where they were treated to a no-holds barred plant tour and inspection. Continue reading
The 2014 Annual Meeting of the Association promises to be a big success, with a beautiful venue, temperatures in line with the spring that it still is, and interesting topics to discuss. Please come and help shape AFCCE policy and direction for the coming years, and enjoy the fellowship of other members of the AFCCE family in a pleasant atmosphere. Continue reading